Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax OJ L 347, 11.12.2006, p 1–118.
A series of groundbreaking directives were adopted recently, most prominently Directive 2016/1164 Laying down Rules against Tax Avoidance Practices that Directly Affect the Functioning of the Internal Market OJL193/1 (‘the ATAD’) and the Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union OJ L328/1 – 58 (the ‘GloBE Directive’).
OECD, Addressing the Tax Challenges of the Digital Economy, Action 1.
The proposal for the creation of such an EU digital levy is not alien to the EU. Famously, the EU had announced that it would introduce its own ‘EU digital levy’ if a global solution did not progress. See, for instance, Matt Thompson, ‘EU Countries Committed to Digital Levy, Leaked Doc Says’, Law 360, 24 March 2021.
J Sadowski, ‘When Data Is Capital: Datafication, Accumulation, and Extraction’ 6 (1) (2019) Big Data & Society, 1–12 at 4.
W Haslehner and M Lamensch, ‘General report on value creation and taxation: outlining the debate’ in W Haslehner and M Lamensch (eds), Taxation and Value Creation (EATLP International Tax Series, IBFD 2021) 25.
For a normative consideration on the characteristics of such a tax see O Marian, ‘Taxing Data’ 47 (2) (2022) Brigham Young University Law Review 511.
That was the case, for instance, with the EU Commission, Proposal for a Council Directive on the common system of a digital services tax on revenues resulting from the provision of certain digital services, 21 March 2018, COM(2018) 148 final (hereinafter the ‘EU DST Proposal’) at 7.
Although this claim is rather questionable, see P Pistone, JF Pinto Nogueira and A Turina, ‘Digital Services Tax: Assessing the Policy Reasons for its Introduction in the European Union’ International Tax Studies (IBFD 4/2021) 4 ff.
The fairness argument on this ground was also made by the European Commission, see Communication from the Commission to the European Parliament and the Council: A Fair and Efficient Tax System in the European Union for the Digital Single Market, COM (2017) 547 final (21 September 2017).
European Commission (2018) Impact Assessment accompanying the document Proposal for a Council Directive laying down rules relating to the corporate taxation of a significant digital presence.
L Corrick, ‘The Taxation of Multinational Enterprises’ in Th Pogge and K Mehta (eds), Global Tax Fairness (Oxford University Press 2016) 173.
Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy 1 July 2021, OECD/G20 Inclusive Framework on BEPS accessed 19 September 2024.
The Pillar Two OECD Model Rules suggest that a minimum corporate tax rate, that is a 15 per cent effective tax rate, should apply to multinational corporations that have had consolidated revenue above EUR 750 million in at least two of the last four fiscal years. It has been implemented in the EU through the GloBE directive (supra, n 2).
For a criticism of the tax, see D Deak, ‘Hungarian Tax on Digital Advertising Services in the Spotlight of Challenges’ 51 (4) (2023) Intertax 309.
Some of these criteria were used in the EU Digital Services Tax Directive Proposal and have been criticised in literature. Indicatively, D Stevanato, ‘A Critical Review of Italy’s Digital Services Tax’ Bulletin for International Taxation (July 2020) 413.
By ‘destination-based’ tax is meant a ‘market jurisdiction’ tax. In other words, a tax imposed by the market state where users or consumers are, or where the services are consumed.
First generation of DSTs include Italy’s levy on digital transactions, Hungary’s advertisement tax and France’s tax on online and physical distribution of audio-visual content.
OECD, Public Consultation Document: Pillar One – Amount A: Draft Multilateral Convention Provisions on Digital Services Taxes and other Relevant Similar Measures (20 December 2022–20 January 2023), available at accessed 19 December 2024.
Ibid., 2.
J Li, ‘The Legal Challenges of Creating a Global Tax Regime with the OECD Pillar One Blueprint’ 75 (2) (2021) Bulletin for International Taxation.
See for instance, J Colliard, L Eden and C Georg, ‘Tax Complexity and Transfer Pricing Blueprints, Guidelines, and Manuals’ 50 (2021) Tax Management International Journal 1.
R Maheshwari, ‘Are the Revenue Sourcing Rules of the OECD’s Pillar One Fulfilling the Objective of Taxing Value Creation?’ 77 (7) (2023) Bulletin for International Taxation.
Amount A that works as an allocative of taxing rights rule applies only to MNEs with revenues higher than EUR 20 billion and with profitability greater than 10 per cent. These thresholds apply at group level (ie to the entire MNE) based on the financial data in an MNE’s consolidated financial statements.
C Brokelind, ‘The Power to Tax in International and EU Tax Law: Who is Sitting Behind the Wheel?’ in J Lindholm and A Hultqvist (eds), The Power to Tax in Europe – Swedish Studies in European Law Volume 14 (Hart Bloomsbury 2023) 191 at 199.
OECD, Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy Frequently asked questions (July 2022) p 4, available at accessed 19 September 2024.
See, eg, R Eccleston, The Dynamics of Global Economic Governance. The Financial Crisis, The OECD and the Politics of International Tax Cooperation (Edward Elgar Publishing 2012), according to whom ‘since the 1960s the broad contours of international tax cooperation have been defined by changing US policy references’, 134.
See also J Sharman, Havens in A Storm. The Struggle for Global Tax Regulation (Cornell University Press 2006);
L Hakelberg, The Hypocritical Hegemon – How the United States Shapes Global Rules against Tax Evasion and Avoidance (Cornell University Press 2020).
US Department of the Treasury, The Made in America Tax Plan (April 2021), available at accessed 19 September 2024.
J Li, ‘China’s Rising (and the United States’Declining) Influence in Global Tax Governance? Some Observations’ 1 (2021) Bulletin for International Taxation 13.
The US has used Section 301 of the US Trade Act of 1974 against those unilateral DSTs to impose trade sanctions on states that allegedly violate international trade agreements or engage in ‘unjustifiable’ or ‘unreasonable’ acts burdening US commerce. In the case of DSTs, the US grievance was not the violation of any trade agreements, but that DSTs effectively discriminated against US corporations: most tech giants that reach the revenue thresholds of DSTs are US tax residents.
Office of the US Trade Representative, ‘USTR announces next steps of Section 301 Digital Services Taxes Investigations’ (26 March 2021).
GAFA stands for the American multinationals that the tax is primarily targeting Google, Apple, Facebook and Amazon. The French DST consists of a 3 per cent tax on companies that generate more than EUR 750 million in global digital sales and more than EUR 25 million of digital sales in France. The tax is imposed on gross revenue from digital services generated in France. According to French outlets the GAFA tax has brought to France 621 million EUR of revenue in 2022, 700 million in 2023 and is expected to bring 800 million in 2024.
See indicatively extracts from the French press: T Sasportas, ‘La taxe GAFA va rapporter 800 millions d’euros en 2024’ (BFM Business 2023), and J Pelois, ‘La taxe Gafa va rapporter gros à la France en 2024: près d’un milliard d’euros!’ (Capital.fr, 09 October 2023).
Office of the United States Trade Representative Ambassador Robert E. Lighthizer, Report on France’s Digital Services Tax Prepared in the Investigation Under Section 301 of the Trade Act of 1974 (2 December 2019) at 77.
D Bunn, ‘Digital Taxes, Meet Handbag Tariffs’, Tax Foundation, 10 July 2020 accessed 19 September 2024.
The Inclusive Framework on BEPS brings together over 140 countries and jurisdictions, including many developing countries, to collaborate on implementation of the BEPS Package.
As per the OECD/G20, ‘Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy’ (8 October 2021) 3: ‘The Multilateral Convention (MLC) will require all parties to remove all Digital Services Taxes and other relevant similar measures with respect to all companies, and to commit not to introduce such measures in the future. No newly enacted Digital Services Taxes or other relevant similar measures will be imposed on any company from 8 October 2021 and until the earlier of 31 December 2023 or the coming into force of the MLC’. Available at accessed 15 September 2025.
OECD/G20 Inclusive Framework’s Task Force on the Digital Economy (TFDE), ‘The Multilateral Convention to Implement Amount A of Pillar One – Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy’, available at accessed 19 September 2024.
OECD Inclusive Framework’s Task Force on the Digital Economy (TFDE), ‘Explanatory Statement to the Multilateral Convention to Implement Amount A of Pillar One – Two Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy’, available at accessed 19 September 2024.
OECD Inclusive Framework’s Task Force on the Digital Economy (TFDE), ‘Understanding on the Application of Certainty for Amount A of Pillar One – Two Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy’, available at accessed 19 September 2024.
R Goulder, ‘Expectations for 2024: Pillar 1 Finds an Off-Ramp’, Tax Notes International (18 December 2023).
M de Wilde, Company Tax Proposals and Tax Policy Initiatives, in Terra/Wattel – European Tax Law. Volume 1: General Topics and Direct Taxation. 8th Student edition at 620 (Wolters Kluwer 2022).
European Parliament, ‘The implementation of the OECD global agreement on re-allocation of taxing rights (Pillar One) In “An Economy that Works for People”’, available at accessed 19 September 2024.
See for instance, C Peters, ‘A Governance Analysis of BEFIT: How the Member States’ Wish to Obtain more Regulatory Authority is Driving a Revolution’ EC Tax Review 2023/5, 195 at 195. In relation to the US, see G Farris, ‘Treasury Secretary Yellen Expects Pillar One Issues to Persist into 2024, US Not Likely to Sign Multilateral Convention in 2023’ (IBFD Tax News Service, 19 October 2023).
C Hennaman, ‘US, India and Saudi Arabia Are Blocking Pillar One; EU Should Prepare Its Own DST on High-Tech Firms, French Finance Minister Says’ (IBFD Tax News Service, 21 February 2023) and G Leali, ‘Le Maire: global digital tax is “blocked” by U.S., India, Saudi Arabia’ (Politico Pro, 20 February 2023).
For an illustration of the potential incompatibilities between Pillar One and the BEFIT proposal see F Scandone, L Scordo and L Marino, ‘Pillar One, Pillar Two and BEFIT – The End of an Unexpected Journey?’ 31 (2024) International Transfer Pricing Journal 1 at 10.
According to Art 38 MLC, all measures listed in Annex A should not apply. Annex A includes the DSTs of Austria, France, Italy and Spain as well as other non-Member States’ DSTs and equalisation levies. See also M Screpante, ‘Digital Services Tax in the European Union: Unsuccessful Implementation of Pillar One? Challenges Ahead’ 205 (2023) International Transfer Pricing Journal 205 at 210 and JM Vázquez, ‘Digital Services Taxes in the European Union: What Can We Expect?’ Kluwer International Tax Blog (14 February 2023), available at accessed 19 September 2024.
Several authors have pointed out how not all participating states in the Inclusive Framework have an equal say in the solutions adopted. See indicatively, R de la Feria, ‘The perceived (un)fairness of the global minimum corporate tax rate’ in W Haslehner, G Kofler, K Pantazatou and A Rust (eds), The ‘Pillar Two’ Global Minimum Tax (Edward Elgar 2024) 58.
European Commission Recommendation of 21 March 2018 relating to the corporate taxation of a significant digital presence, COM(2018) 1650 final.
European Commission, Proposal for a Council Directive laying down rules relating to the corporate taxation of a significant digital presence, 21 March 2018, COM (2018) 147 final.
The other two covered services were: ‘(a) the placing on a digital interface of advertising targeted at users of that interface; (b) the making available to users of a multi-sided digital interface which allows users to find other users and to interact with them, and which may also facilitate the provision of underlying supplies of goods or services directly between users.’
EU DST Proposal, Art 5.
EU DST Proposal, Preamble, recital 6.
EU DST Proposal, Preamble, recital 5.
EU DST Proposal, Preamble., recital 6.
Y Brauner, ‘Taxing the Digital Economy Post-BEPS Seriously’ 46 (2018) Intertax 462 at 464.
J Becker and J Englisch, ‘EU Digital Services Tax: A Populist and Flawed Proposal’ in Kluwer International Tax Blog (16 March 2018), available at accessed 19 September 2024; Pistone et al, supra (n 10).
G Kofler and J Sinnig, ‘Equalization taxes and the EU’s ‘digital services tax’’ in W Haslehner, G Kofler, K Pantazatou and A Rust (eds), Tax and the Digital Economy: Challenges and Proposals for Reform (Wolters Kluwer 2019) 101 at 139, see W Cui, The Digital Services Tax: A Conceptual Defense 73 (2020) Tax L. Rev. 69.
Vázquez, supra (n 48).
G Kofler, The Future of Digital Services Taxes, EC Tax Review 2021/2, 50 at 51.
Cui, supra (n 60);
YR Kim, ‘Digital Services Tax: A Cross-Border Variation of the Consumption Tax Debate’ 72 (2020) Alabama Law Review 131;
D Shaviro, Digital Services Taxes and the Broader Shift from Determining the Source of Income to Taxing Location-Specific Rents, NYU Law and Economics Research Paper No 19–36.
Cui, supra (n 60) 69 at 72.
Council Regulation (EU) 2020/2094 of 14 December 2020 establishing a European Union Recovery Instrument to support the recovery in the aftermath of the COVID-19 crisis (2020)OJ L433 I/23 (EURI Regulation).
On the legal issues around this debt issuance see B De Witte, ‘The European Union’s COVID-19 Recovery Plan: The Legal Engineering of an Economic Policy Shift’ 58 (2021) Common Market Law Review 635.
Until recently the only own resources were custom duties from imports outside the EU, Gross National Income (GNI)based and VAT-based own resources.
The costs are estimated to be at least €15 billion EUR per year until 2058 on average. Regarding these concerns see for instance, European Parliament, ‘EU revenue: a new start for EU finances, a new start for Europe Press Release’ (10 May 2023) available at accessed 19 September 2024.
See for instance F Vanistendael et al, ‘European Solidarity requires EU taxes’ (Op-Ed EU Law Live, 21 April 2020) accessed 19 September 2024.
Currently, Council Decision (EU, Euratom) 2020/2053 of 14 December 2020 on the system of own resources of the European Union and repealing Decision 2014/335/EU, Euratom, OJ 2020 L 424/1.
See indicatively, J Lindholm and A Hultqvist (eds), The Power to Tax in Europe – Swedish Studies in European Law Volume 14 (Hart Bloomsbury 2023).
K Pantazatou, ‘Revising the Justification for an EU Tax in a Post-crisis Context’ in D de Cogan, A Brassey and P Harris (eds) Tax Law in Times of Crisis and Recovery (Hart Publishing 2023) 135 at 143.
High Level Group on Own Resources, ‘Future Financing of the EU, Final report and recommendations of the High Level Group on Own Resources’ (December 2016) 24, accessed 19 September 2024.
C Waldhoff, ‘Legal Restrictions and Possibilities for Greater Revenue Autonomy of the EU’ in T Büttner and M Thöne (eds), The Future of EU Finances (Mohr Siebeck 2016).
Pantazatou, supra (n 72) 143.
High Level Group on Own Resources, supra (n 73).
Art 192 TFEU.
Art 194 TFEU.
Arts 113–15 TFEU.
C Sciancalepore, The Reform of EU Own Resources under the Next Generation EU Programme: A Suitable Moment for the Introduction of a European Tax? in The Power to Tax (Hart Bloomsbury 2023) 123 at 134.
European Council, Note: Conclusions of the Special Meeting (21 July 2020) EUCO 10/20, available at accessed 19 September 2024.
Own Resources Decision (n 70).
F Vanistendael, ‘Remembering 2020’ 101 (2021) 101 Tax Notes International 334. Cf Sciancalepore (supra, n 81) who argues that the ‘plastic tax’ seems to be configured more as a contribution by the Member States than as a proper tax levied on EU citizens.
European Commission, Public Consultation, A fair & competitive digital economy – digital levy, available at accessed 19 December 2024.
Own Resources Decision, para 5.
European Commission, Inception Impact Assessment, Ref Ares(2021)312667.
European Commission, ‘The next generation of own resources for the EU Budget’ (Communication) COM (2021) 566 final.
European Commission, ‘Proposal for a Regulation of the European Parliament and of the Council Establishing a carbon border adjustment mechanism’ COM(2021) 564 final.
European Commission, supra (n 89).
European Commission Press Release, The Commission proposes the next generation of EU own resources (22 December 2021), available at accessed 19 September 2024.
See for instance CFE Tax Advisers Europe, European Union – Opinion Statement CFE 2/2021 on the EU Digital Levy Consultation, European Taxation, 2021 (Volume 61) No 8.
For an excellent policy and tax design analysis see Pistone et al, supra (n 10).
See for instance, W Redmar, ‘The EU Digital Levy is Dead: Long Live a Pillar One Contribution?’ 62 (2/3) (2022) European Taxation 132–5.
S Kostić and A Navarro, ‘Pillar One and Mobility – A Truly Global Solution?’ 51 (12) (2023) Intertax 840–50;
J White, ‘Opinion: Pillar One Might Already be Doomed’ (2023) International Tax Review.
While the extensive legislation in direct taxation proves otherwise, there is still a theoretical debate on whether the Union has competence in the area of taxation. The existing directives in direct taxation have been based on Art 115 TFEU and have resulted from the need to ensure the functioning of the internal market. It is highly unlikely that the introduction of an EU digital levy or an EU legislative framework on DSTs would be blocked on grounds of a lack of competence.
In favour of such solution see indicatively, AB Moreno and Y Brauner, ‘Taxing the Digital Economy Post BEPS::: Seriously’ 58 (2019) Columbia Journal of Transnational Law 131 ff;
Y Brauner and P Pistone, ‘Adapting Current International Taxation to New Business Models’ 71 (12) (2017) Bulletin for International Taxation 681.
See indicatively, P Hongler and P Pistone, ‘Blueprints for a New PE Nexus to Tax Business Income in the Era of the Digital Economy, WU International Taxation Research Paper Series No. 2015 - 15 (20 January 2015), available at accessed 19 September 2024;
Brauner and Pistone supra (n 98).
European Commission Press Release supra (n 92).
Commission’s position expressed in the Q&A of December 2021. See The next generation of EU own resources: European Commission, Questions and Answers – Brussels, 22 December 2021.
The ample CJEU case law on the interaction of fundamental freedoms and direct tax systems has resulted in the removal of discriminatory domestic tax measures, whereas recent secondary EU direct tax law has primarily aimed at combating tax avoidance practices (eg the ATAD directive, supra, n 2).
According to T Woźniakowski ‘[F]iscalisation is a process through which a certain level of government (supranational, federal, central) expands its power to raise its own sources of revenue, and in so doing it decreases the level of vertical fiscal imbalance’ in T Woźniakowski, Fiscal Unions: Economic Integration in Europe & the United States (Oxford University Press 2022) 10.
The below mentioned considerations are certainly affected by the tax design. For instance, ‘fairness’ considerations would seriously be put at risk in case the tax introduced was discriminatory and introduced multiple levels of taxation to the taxpayers. See with regard to this Pistone et al, supra (n 10).
See for instance, Decision (EU) 2022/2481 of the European Parliament and of the Council of 14 December 2022 establishing the Digital Decade Policy Programme 2030, OJ L 323, 19.12.2022, p 4.
Y Bury and LP Feld, Fiscal federalism in Germany in J-F Tremblay (ed), The Forum of Federations Handbook of Fiscal Federalism (Palgrave Macmillan 2023) 159.
C Fuest, Friedrich Heinemann and Martin Ungerer, ‘Reforming the Financing of the European Union: A Proposal’ 50 (5) (2015) Intereconomics 288.
The benefit theory views taxes as a ‘price’ or consideration to be paid by all taxpayers for the public goods and services provided in a state. Several different expressions of the benefit principle have been put forward, see J Buchanan, Fiscal Theory and Political Economy, Selected Essays (The University of North Carolina Press 1960) 7 ff;
J Dodge, ‘Theories of Tax Justice: Ruminations on the Benefit, Partnership, and Ability-to-Pay Principles’ 58 (2005) Tax Law Review 399. In this case, the benefit the taxpayers receive would consist of legislation around the digital economy, including the GDPR or the AI Act.
European Commission, ‘The Added Value of the EU budget’ Commission Staff Working Paper SEC (2011) 867 final, 2.
J Jaakkola, ‘A Justification for the EU’s Power to Levy Taxes’ in J Lindholm and A Hultqvist (eds), The Power to Tax in Europe – Swedish Studies in European Law Volume 14 (Hart Bloomsbury 2023) 59 at 76.
A Wagner, ‘Three Extracts on Public Finance’ in RA Musgrave and AT Peacock (eds), Classics in the Theory of Public Finance, 4th edn (Macmillan, St Martin’s Press 1967) ix.
See also S Geringer, ‘(In)congruence Between Taxation, Spending, and Representation: The Ambiguous Character of Tax-based Contributions’ 52 (8 and 9) (2024) Intertax 558 who argues that although an EU own resources system that is (primarily) financed through tax-based contributions could fundamentally help to mitigate the effects of the declining congruence between taxation, spending, and representation in relation to EU citizens in certain respects, it would itself simultaneously create issues of democratic legitimacy in other contexts.
Although it has to be acknowledged at this stage that this under the current EU legal framework would be a difficult undertaking.
See indicatively, MP Maduro, A new governance for the European Union and the Euro: Democracy and Justice, RSCAS Policy Papers RSCAS PP 2012/11, p 7;
AJ Menéndez, ‘Taxing Europe: Two Cases for a European Power to Tax (with some
comparative observations)’ 10 (2003–04) Columbia Journal of European Law 297 at 311 ff;
T Woźniakowski, Fiscal Unions: Economic Integration in Europe & the United States (Oxford University Press 2022) at 150 ff;
Pantazatou (supra, n 72) at 139 ff.
Woźniakowski, supra, p 150, RG Antón, ‘Building up the EU Revenue Side: But What Is a Tax in EU Law?’ 11 (4) (2023) Politics and Governance 17.
Woźniakowski, supra, while discussing the Portuguese position, p 123.
C Brokelind, ‘EU Tax Law and the Return of the Nation-State’ in A Bakardjieva Engelbrekt et al (eds), The European Union and the Return of the Nation State (Springer International Publishing 2020) 146.
See the procedure under Art 311 (3) TFEU.
See CFE Tax Advisers Opinion, supra (n 93).
Wagner, supra (n 111).
See above, section 2a. G20 Press release (‘Leaders’ Communiqué’), Brisbane, 15–16 November 2014, available at accessed 15 September 2024, where the OECD stated that: ‘We are taking actions to ensure the fairness of the international tax system and to secure countries’ revenue bases. Profits should be taxed where economic activities deriving the profits are performed and where value is created.’
European Commission, Incentive Impact Assessment.
D de Cogan, ‘Mapping Tax Justice Arguments’ in D de Cogan and P Harris (eds), Tax Justice and Tax Law: Understanding Unfairness in Tax Systems (Hart Publishing 2020) 2.
See Wagner, supra (n 111);
K Tipke, Die Steuerrechtsordnung Band I: Wissenschaftsorganisatorische, systematische und grundrechtlich-rechtsstaatliche Grundlagen (2, völlig überarbeitete Auflage) (Köln, Verlag Dr. Otto Schmidt 2000) at 484.
Although, as discussed before the nexus between the digital tax and a potentially expected ‘digital output’ is loose.
J Jaakkola, ‘A Democratic Dilemma of European Power to Tax: Reconstructing the Symbiosis Between Taxation and Democracy Beyond the State?’ 20 (2019) German Law Journal 660 at 677.
M Schratzenstaller et al, ‘EU Taxes as genuine own resources to finance the EU budget. Pros cons and sustainability-oriented criteria to evaluate potential tax candidates’ (2016) FairTax Working Paper no 3;
J Martinez-Vazquez, C McLure and F Vaillancourt, ‘Revenues and Expenditures in an Intergovernmental Framework’ in R Bird and F Vaillancourt (eds), Perspectives on Fiscal Federalism (World Bank 2006) 15–34.
See Y Brauner, ‘Taxation of Information and the Data Revolution’ (23 March 2023), available at accessed 19 September 2024.
J Bachtler, C Mendez and F Wishlade, EU Cohesion Policy and European Integration – The Dynamics of EU Budget and Regional Policy Reform (Ashgate 2013) 130.
See for instance the opposition voices raised by the Netherlands and Denmark during the Agenda 2000 debate and by Sweden, the UK and Germany during the 2000–2005 period in Bachtler et al 2013 (supra, n 129) 130.
For the VAT as a national transfer see Menéndez, supra (n 114) 300. For the general perception and nature of own resources see M Schratzenstaller, A Krenek, D Nerudova and M Dobranschi, ‘EU Taxes as genuine own resource to finance the EU budget – pros, cons and sustainability-oriented criteria to evaluate potential tax candidates’, FairTax Working Paper Series no 3 (diva-portal.org, June 2016) accessed 15 September 2025.
